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Question 21

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What are two sources for maintaining up-to-date sanctions information? (Choose two.)

U.S. Federal Bureau of Investigation's National Security Letters

U.S. Federal Bureau of Investigation's National Security Letters

U.S. Department of the Treasury Office of Foreign Assets Control

U.S. Department of the Treasury Office of Foreign Assets Control

U.S. Department of the Treasury -- Section 311 -- Special Measures

U.S. Department of the Treasury -- Section 311 -- Special Measures

Financial Action Task Force's list of High Risk and Non-Cooperative Jurisdictions

Financial Action Task Force's list of High Risk and Non-Cooperative Jurisdictions

Suggested answer: B, D
Explanation:

The U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals. OFAC publishes lists of individuals and entities that are subject to various sanctions programs, such as the Specially Designated Nationals and Blocked Persons List (SDN List), the Sectoral Sanctions Identifications List (SSI List), and the Foreign Sanctions Evaders List (FSE List).These lists are updated frequently and can be accessed through OFAC's website or other sources12.

The Financial Action Task Force (FATF) is an inter-governmental body that sets standards and promotes effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and other related threats to the integrity of the international financial system. FATF publishes lists of jurisdictions that have strategic deficiencies in their anti-money laundering and counter-terrorist financing (AML/CTF) regimes, and calls on its members and other countries to apply enhanced due diligence or counter-measures to protect themselves from the risks emanating from these jurisdictions.These lists are updated periodically and can be accessed through FATF's website or other sources34.

1: CAMS Certification Package - 6th Edition | ACAMS, Chapter 3: Sanctions, p.63-642: U.S.Department of the Treasury Office of Foreign Assets Control, https://home.treasury.gov/policy-issues/financial-sanctions3: CAMS Certification Package - 6th Edition | ACAMS, Chapter 4: FATF Recommendations, p.77-784: Financial Action Task Force, http://www.fatf-gafi.org/countries/#high-risk

asked 27/11/2024
Alberto Castillo
38 questions

Question 22

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A bank has maintained an account for a European charity for several years. The charity provides clothing to persons in need in various countries with active terrorists' cells.

Which action by the charity indicates possible terrorist financing?

The charity frequently withdraws cash from the bank

The charity frequently withdraws cash from the bank

The charity has branch locations located in various countries

The charity has branch locations located in various countries

The charity receives cash donations primarily from European countries

The charity receives cash donations primarily from European countries

The charity maintains a bank account for non-business-related expenses

The charity maintains a bank account for non-business-related expenses

Suggested answer: A
Explanation:

The charity frequently withdrawing cash from the bank indicates possible terrorist financing, as cash transactions are often used to conceal the source, destination, and purpose of funds. Cash transactions also make it difficult to trace the flow of funds and identify the beneficiaries.Terrorist financiers may use charities as a cover to collect and distribute funds for their activities, and may exploit the cash-based nature of charitable donations to avoid detection12.

20Typologies%20Report.pdf

asked 27/11/2024
Rama Krishna
42 questions

Question 23

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A politically exposed person (PEP) maintains an account at a bank. Last month a money laundering analyst filed a suspicious transaction report about unusual wire deposits originated by unknown individuals in the home country of the official.

To whom should this situation be escalated?

The board of directors

The board of directors

The line of business executive

The line of business executive

The bank's anti-money laundering officer

The bank's anti-money laundering officer

The Financial Action Task Force's PEP Hotline

The Financial Action Task Force's PEP Hotline

Suggested answer: C
Explanation:

According to the ACAMS CAMS Certification Study Guide (6th edition), the bank's anti-money laundering officer is responsible for overseeing the implementation and maintenance of the bank's anti-money laundering program, which includes reporting and escalating suspicious activities involving PEPs. The anti-money laundering officer should be informed of any unusual or potentially illicit transactions involving PEPs, and decide on the appropriate course of action, such as filing additional reports, conducting enhanced due diligence, or terminating the relationship with the PEP. The other options are not correct because they are either not directly involved in the anti-money laundering program, or not the appropriate authority to contact in this situation.

asked 27/11/2024
Nathalie Agustin
38 questions

Question 24

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Which two individuals are ordinarily beneficial owners of a private banking account according to the Wolfsberg Anti-Money Laundering Principles for Private Banking? (Choose two.)

Those two are authorized signers on the account

Those two are authorized signers on the account

Those who have legal title to a controlling share interest in the customer

Those who have legal title to a controlling share interest in the customer

Those who generally have ultimate control through ownership or other means over the funds in the account

Those who generally have ultimate control through ownership or other means over the funds in the account

Those who are the ultimate source of funds for the account and whose source of wealth should be subject to due diligence

Those who are the ultimate source of funds for the account and whose source of wealth should be subject to due diligence

Suggested answer: C, D
Explanation:

According to the Wolfsberg Anti-Money Laundering Principles for Private Banking, the beneficial owners of a private banking account are those who generally have ultimate control over the funds in the account and those who are the ultimate source of funds for the account and whose source of wealth should be subject to due diligence1. These two criteria are meant to ensure that the bank knows who is ultimately behind the account and where the funds come from, in order to prevent the use of the bank for money laundering or other criminal purposes. Authorized signers on the account or those who have legal title to a controlling share interest in the customer are not necessarily the beneficial owners, as they may act on behalf of others or have limited influence over the account.

20Wolfsberg-Private-Banking-Prinicples-May-2012.pdf (2)

asked 27/11/2024
Sushil Karki
47 questions

Question 25

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What are two requirements for monitoring and reporting suspicious activity for correspondent banking according to the Wolfsberg Principles? (Choose two.)

Incorporate suspicious activity monitoring into periodic reviews

Incorporate suspicious activity monitoring into periodic reviews

Incorporate due diligence results such as customer risk ratings

Incorporate due diligence results such as customer risk ratings

Utilize downstream correspondents to investigate and report suspicious activity

Utilize downstream correspondents to investigate and report suspicious activity

Investigate and report suspicious activity only for the correspondent bank's clients

Investigate and report suspicious activity only for the correspondent bank's clients

Suggested answer: A, B
Explanation:

'https://www.wolfsberg-principles.com/sites/default/files/wb/pdfs/wolfsberg-standards/8.%20Wolfsberg-Correspondent-Banking-Principles-2014.pdf - page 6 Monitoring and Reporting of Suspicious Activities The institution shall implement bank-wide policies and procedures to detect and investigate unusual or suspicious activity and report any such activity as required by applicable law. These will include guidance on what is considered to be unusual or suspicious and give examples thereof. The policies and procedures shall include appropriate monitoring of the Correspondent Bank's activity, incorporating due diligence results such as customer risk rating and other factors considered meaningful in the assessment of transaction activity risk. In turn, the results of suspicious activity monitoring shall be factored into the periodic review of the client's file, particularly when the results of transaction monitoring indicate elevated risk levels.

asked 27/11/2024
Korrakot Tianniam
38 questions

Question 26

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When should the anti-money laundering risk assessment be updated?

Every two years

Every two years

After a merger or acquisition

After a merger or acquisition

When the board of directors changes

When the board of directors changes

When instructed to by the Financial Action Task Force

When instructed to by the Financial Action Task Force

Suggested answer: B
Explanation:

Evaluating the risk scoring model and conducting the risk assessment itself may need to be performed annually, every eighteen to twenty-four months, before the launch of a new product, or when an acquisition of another financial institution occurs.

Assessment-FAQs-2015.pdf (10)

asked 27/11/2024
Pedro Faro
38 questions

Question 27

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A customer brings $15,000 worth of chips into a casino and plays various games. The customer redeems all the remaining chips and requests a wire transfer of the proceeds to an unrelated third party.

What are two red flags that indicate money laundering? (Choose two.)

Customer redeeming all remaining chips

Customer redeeming all remaining chips

Playing various games before cashing out

Playing various games before cashing out

Bringing $15,000 worth of chips into the casino

Bringing $15,000 worth of chips into the casino

Requesting a wire transfer to an unrelated third party

Requesting a wire transfer to an unrelated third party

Suggested answer: C, D
Explanation:

Bringing $15,000 worth of chips into the casino is a red flag because it could indicate that the customer is trying to avoid the currency transaction reporting (CTR) requirement for cash transactions over $10,0001.Requesting a wire transfer to an unrelated third party is another red flag because it could indicate that the customer is trying to conceal the source or destination of the funds, or transfer them to a high-risk jurisdiction2.

1: ACAMS CAMS Certification Video Training Course, Module 3: Casinos and Gaming, Section 3.1: Regulatory Requirements, Slide 82: ACAMS CAMS Certification Video Training Course, Module 3: Casinos and Gaming, Section 3.2: Money Laundering Methods and Red Flags, Slide 11

asked 27/11/2024
Nakli Pun
35 questions

Question 28

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A United States (U.S.) bank was recently alerted by law enforcement of an increase in sale of large denomination U.S. bank notes to casas de cambio. They suspect that a Mexican syndicate is operating a money laundering scheme in the bank's jurisdiction.

Which two steps should be taken to trace funds through the bank to assist law enforcement in their investigation? (Choose two.)

Identify the money laundering scheme and submit a suspicious transaction report

Identify the money laundering scheme and submit a suspicious transaction report

Identify if there is a decrease in the sale of large denomination U.S. bank notes to casas de cambio by the bank

Identify if there is a decrease in the sale of large denomination U.S. bank notes to casas de cambio by the bank

Identify deposits by casas de cambio that include third-party items including sequentially numbered monetary instruments

Identify deposits by casas de cambio that include third-party items including sequentially numbered monetary instruments

Identify multiple wire transfers initiated by casas de cambio to jurisdictions outside of Mexico that bear no apparent business relationship with that casa de cambio

Identify multiple wire transfers initiated by casas de cambio to jurisdictions outside of Mexico that bear no apparent business relationship with that casa de cambio

Suggested answer: A, D
Explanation:

According to the ACAMS Study Guide 6th Edition, Chapter 2, page 38, one of the steps that a financial institution should take when it suspects money laundering activity is to file a suspicious transaction report (STR) or a suspicious activity report (SAR) to the relevant authorities. This will alert the regulators and law enforcement of the potential money laundering scheme and provide them with valuable information to trace the funds and identify the perpetrators.

Another step that a financial institution should take is to identify any unusual or suspicious wire transfers initiated by casas de cambio to jurisdictions outside of Mexico that bear no apparent business relationship with that casa de cambio. This could indicate that the casas de cambio are involved in layering and integration stages of money laundering, where they are moving the illicit funds across borders and disguising their origin and ownership. The financial institution should monitor and document these wire transfers and report them to the authorities if necessary.

Option B is not a relevant step to trace funds through the bank, as it does not provide any information about the source, destination, or purpose of the funds. A decrease in the sale of large denomination U.S. bank notes to casas de cambio by the bank could be due to various factors, such as market demand, exchange rates, or regulatory changes, and does not necessarily indicate money laundering activity.

Option C is also not a relevant step to trace funds through the bank, as it does not indicate any connection to the suspected money laundering scheme. Deposits by casas de cambio that include third-party items, such as sequentially numbered monetary instruments, could be legitimate transactions that are part of the normal business operations of the casas de cambio. Unless there is evidence that these deposits are related to the sale of large denomination U.S. bank notes or the Mexican syndicate, they are not useful for tracing the funds.

ACAMS Study Guide 6th Edition, Chapter 2, page 38

Combating Money Laundering and Other Forms of Illicit Finance

Sting Operation Snares Casa de Cambio for Allegedly Laundering Millions Through U.S. Banks

asked 27/11/2024
Jari Tetteroo
47 questions

Question 29

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Which two factors assist a money laundering investigation that involves multiple countries? (Choose two.)

Law enforcement and other authorities should have access to financial information that is pertinent to the investigation.

Law enforcement and other authorities should have access to financial information that is pertinent to the investigation.

Every country should share all their information with foreign law enforcement and government authorities to facilitate rapid investigations.

Every country should share all their information with foreign law enforcement and government authorities to facilitate rapid investigations.

Law enforcement and other authorities should be allowed to establish and utilize joint investigative teams with law enforcement in other countries.

Law enforcement and other authorities should be allowed to establish and utilize joint investigative teams with law enforcement in other countries.

Law enforcement and other authorities should not expedite information sharing between countries to ensure that all information is provided at the same time to avoid premature conclusions.

Law enforcement and other authorities should not expedite information sharing between countries to ensure that all information is provided at the same time to avoid premature conclusions.

Suggested answer: A, C
Explanation:

A money laundering investigation that involves multiple countries can be challenging due to different legal systems, languages, cultures, and levels of cooperation. Two factors that can assist such an investigation are:

Law enforcement and other authorities should have access to financial information that is pertinent to the investigation. This can help them trace the flow of illicit funds, identify the perpetrators and beneficiaries, and gather evidence for prosecution. Financial information can be obtained from various sources, such as financial institutions, financial intelligence units, regulators, and international organizations.

Law enforcement and other authorities should be allowed to establish and utilize joint investigative teams with law enforcement in other countries. This can enhance coordination, communication, and information sharing among the authorities involved, and allow them to pool resources, expertise, and evidence. Joint investigative teams can also facilitate mutual legal assistance and extradition requests.

Financial Action Task Force (FATF), International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation, The FATF Recommendations, February 2012, updated June 2019, Recommendation 40, pp. 120-123

FATF, Best Practices on Establishing and Operating a Joint Investigative Team, June 2020, pp. 5-6

FATF, Money Laundering and Terrorist Financing Investigations, June 2018, pp. 11-12

asked 27/11/2024
Aziz ZENNOUN
32 questions

Question 30

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A popular restaurant in town has begun depositing less cash than it has in prior years. In a review of the customer's accounts, you notice that credit card receipts have increased with no .

The account officer discovers that the restaurant has installed a privately-owned automated teller machine (ATM) onsite and has begun construction on a patio dining area.

Which red flag should trigger additional investigation?

Privately-owned ATM

Privately-owned ATM

Lower cash deposits

Lower cash deposits

Increased credit card receipts

Increased credit card receipts

Construction of the new patio dining area

Construction of the new patio dining area

Suggested answer: A
Explanation:

According to the ACAMS study guide, one of the red flags for money laundering in cash-intensive businesses is ''the presence of privately-owned ATMs on the premises'' (p. 222). This could indicate that the business is using the ATM to deposit or withdraw large amounts of cash from illicit sources, or to facilitate the movement of funds across borders. The other options are not necessarily indicative of money laundering risk, as they could be explained by legitimate factors such as the change in customer preferences, the economic situation, or the expansion of the business.

ACAMS. (2020).Study Guide for the Certification Examination for Anti-Money Laundering Specialists (6th ed.). Miami, FL: ACAMS.

CFI.(2023)Money Laundering - Overview, How It Works, Example1. Retrieved from https://corporatefinanceinstitute.com

CALERT.(2016)How Do Criminals Launder Money Through a Restaurant?2. Retrieved from https://calert.info

asked 27/11/2024
Jay Barre
44 questions
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